...the 2026 NATP Taxposium at the Cleveland Convention Center next week. Session Overview: IRS Enforcement of Foreign Asset & Income Reporting In his upcoming presentation, IRS Enforcement of Foreign Asset...
...The failure to report the account on a timely filed FBAR was not willful; The failure to report the account on a timely filed FBAR was due to reasonable cause;...
...remedial measures designed to reimburse the government for enforcement costs and encourage compliance, which would exempt them from constitutional constraints. The appellate court explicitly rejected the government’s characterization. The court...
The enforcement landscape surrounding the Paycheck Protection Program (PPP) has entered a highly aggressive enforcement phase. What began as an administrative process managed by the Small Business Administration (SBA) has...
...using standard administrative mechanisms like liens, levies, and account offsets. The Stand-Alone Civil Suit Theory: The taxpayer argued that because Section 6039F resides in Chapter 61 rather than Chapter 68,...
...(IRC) Section 7508A, which governs the postponement of certain tax deadlines by reason of a presidentially declared disaster. In 2019, Congress enacted subsection (d) to provide a mandatory, self-executing suspension...
...When a partner passes away, a timely election under Section 754 allows the partnership to adjust the basis of its internal assets under Section 743(b). This ensures that the deceased...
...The federal tax treatment of a foreign trust depends entirely on whether the entity is classified as a grantor trust or a non-grantor trust under Internal Revenue Code Sections 671...
...when a client operates a highly valuable business through a pass-through entity, such as a multi-member LLC treated as a partnership for tax purposes. Under IRC § 1202(i)(1), when a...
...for challenging accuracy-related penalties, it is often a fact-intensive uphill battle. Fortunately, the Internal Revenue Service (IRS) maintains an administrative relief mechanism that bypasses the need to establish reasonable cause...
...be equally unable to pay after a criminal investigation or civil examination, but the government will have expended far greater enforcement resources to reach the same result. As the comments...
...More than the Correct Amount of Tax. How We Can Help Until these legislative changes are enacted, tax professionals must ensure strict adherence to both reporting regimes. The interaction between...
